¹The $10,000 amount is adjusted after 1998 for inflation under Sec. 2503(b)(2), but only in increments of $1,000; it did not change for 1999 and 2000.

²See Regs. Sec. 25.2512-3 and -2(f)(2); Rev. Ruls. 59-60, 1959-1 CB 237 and 93-12, 1993-1 CB 202.

³See, e.g., Est. of Maude G. Furman, TC Memo 1998-157, in which the Tax Court allowed a 40% combined lack of marketability and minority interest discount for transfers of interests in a closely held business.

⁴See Secs. 2504(c) and 2001(f).

⁵If the estate, gift and GST tax regimes are repealed (as was proposed by the last Congress), the benefit could actually become a detriment.

⁶D. Clifford Crummey, 397 F2d 82 (9th Cir. 1968).

⁷The GST exemption is indexed after 1998 for inflation under Sec. 2631(c) and was increased to $1,030,000 for 2000; see Rev. Proc. 99-42, IRB 1999-46, 568.

⁸See generally, McCaffrey and Schneider, "Planning for GRATs and QPRTs; Large Retirement Accounts; Sophisticated Estates," presented in Valuation, Taxation & Planning Techniques for Sophisticated Estates 2000, 287 PLI/Est 243 (2000).

⁹Compare Est. of D. Byrd Gwinn, 25 TC 31 (1955), acq., 1956-1 CB 4.

¹⁰Although it is possible to calculate actuarial factors manually, using the tables provided in Regs. Sec. 20.2031-7 and IRS Pubs. 1457, Actuarial Values, Book Aleph, 1458, Actuarial Values, Book Beth and 1459, Actuarial Values, Book Gimel, it is generally simpler to use a commercial software package for the calculations. The calculations in this article were prepared using either NumberCruncher '99, by Leimberg and LeClair, Planned Giving Manager, by PG Calc, or Factors, by U.S. Trust Company.

¹¹See Sec. 2513(a)(1) and Regs. Sec. 25.2513-1(a) and (b)(4).

¹²See, e.g., Regs. Sec. 25.2702-3 and note 8, supra.

¹³See, e.g., NYS Estates, Powers and Trusts Law 7-1.9.

¹⁴See, e.g., Michael Ferguson, 108 TC 244 (1997), aff'd, 164 F3d 997 (9th Cir. 1999).

¹⁵See IRS Letter Ruling (TAM) 200011005 (11/23/99).

¹⁶See, e.g., IRS Letter Rulings 9922007 (2/10/99), 9908002 (11/5/98), 9713017 (12/27/96), 9648045 (9/3/96), 9645013 (8/9/96) and 9642039 (7/18/96).

¹⁷See note 11, supra.

¹⁸See Handler and Dunn, "Guaranteed GRATs: GRATs Without Mortality Risk," 138 Trusts & Estates 30 (December 1999).